SGIA Takes Action

SGIA Takes Action

In a letter to the Colorado Air Polllution Control Division, SGIA supported the new proposed language included in the Agency's proposed Industrial Solvent Cleaning Rule. The state is proposing to exempt both digital and screen printing operations from the requirements of this new regulation. The state's actions are in line with actions taken by other states. For more information, please contact Marci Kinter at govtaffairs@sgia.org.

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A recent regulatory package issued by the Massachusetts Department of Environmental Protection (DEP) proposed changes that would impact the Printer’s Environmental Results Program, or ERP. The ERP program is the regulatory program for printing facilities operating in the state. The DEP proposed, and SGIA supported, a new classification for a “Very Small Printer.”

The proposed amendments include creating a new category of printer called a Very Small Printer (VSP). A VSP is defined in the proposed amendments as those printers that meet all of the following requirements:
• are connected to a municipal sewer,
• generate no more than 55 gallons of hazardous waste per year,
• use no more than 55 gallons of cleanup solution per year, and
• use no more than 55 gallons of alcohol per year.

If adopted, those facilities that can be qualified as Very Small Printers would only be required to file a one-time, rather than an annual, certification and would not pay a corresponding fee.

The comments also recommended the inclusion of a definition for digital printing so that facilities operating digital presses could also qualify under this definition.

SGIA continues to monitor this important state regulatory development.

The U.S. Environmental Protection Agency is currently proposing to amend the Accidental Release Prevention Requirements of Risk Management Programs (RMP) under the Clean Air Act, Section 112(r)(7). The proposed changes are the result of a government effort to reduce chemical accidents, which became a federal priority after an explosion in West, Texas in 2013. Some of the revisions proposed by EPA that may impact printing facilities include:

Clarifying language, such as substituting the term “imminent and substantial endangerment” with the phrase “impacts that resulted in deaths, injuries, or significant property damage on-site, or known offsite deaths, injuries, evacuations, sheltering in place, property damage, or environmental damage.”

Inclusion of a root cause analysis in investigations, which would require facilities to determine what caused an accident and would be included in RMP accident history reports.

Requirement that facility owners and operators complete incident investigations within 12 months of either a catastrophic release or a near miss and would allow extensions of time for complex incidents, if approved by the agency in writing.

More stringent audit requirements for program 2 and 3 facilities.

Requirement that audit reports and documentation be submitted to the implementing agency and be available to the public

Requirement that the owner or operator of a program 2 or 3 facility must coordinate with local response authorities to ensure that appropriate resources and capabilities are in place to respond to an accidental release of a regulated substance. If local emergency response capabilities are not adequate, EPA proposes that the facility be required to develop its own emergency response program.

Development of a “score card” or grade system for RMP facilities. This grade would be available to the public.

SGIA has submitted comments to the EPA and will continue tracking updates on this proposal. Sign up to receive the most up-to-date regulatory and legislative information about specialty imaging.

The Occupational Safety and Health Administration (OSHA) held a public stakeholder review of its revised Safety and Health Program Management Guidelines. The meeting, held March 10, provided OSHA representatives an opportunity to hear directly from interested parties and discuss comments received by OSHA on this update. Marci Kinter, SGIA Vice President – Government & Business Information, participated in the meeting. Discussion topics included: management leadership principles; worker participation; hazard identification; hazard prevention and control as well as education and training. OSHA anticipates publishing its final guidance in the Summer of 2016. This guidance document replaces the Agency’s 1989 guidance of the same topic.

North Carolina’s Department of Environmental Quality has issued a proposed rule to simplify the rule outlining activities exempted from permit requirements. The proposed language would exempt from permitting facilities with actual emissions of less than five tons per year of each of the following: volatile organic compounds, hazardous air pollutants, particulate matter (PM10), sulfur dioxide, nitrogen oxides, carbon monoxide, or toxic air pollutants. To determine applicability, a facility would be asked to determine actual emissions of each pollutant emitted. If actual emissions are less than 5 tons for each of the aforementioned, then the facility is exempt from permitting. However, a facility’s actual emissions of all these pollutants combined exceed 10 tons per year, and then a permit is required. The state is also proposing a registration permit for facilities whose combined emissions are greater than 5 tons but less than 25 tons.

In a comment submitted to the Department, SGIA indicated overall support for the changes as outlined by the Department to Rule 15A NCAC02Q.0102, Activities Exempted from Permit Requirements; however, we requested that the Department clarify that the permit exemptions will also apply to those facilities using screen and/or digital imaging technologies as their chosen print processes. The current definition for graphic arts, as contained in 15A NCAC 02Q.0803 does not reference either of these technologies.

SGIA continues to support the Department’s move to simplify the state air permitting system for these small and very small facilities; however, we need to ensure that the requirements will apply to both screen and digital facilities.

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